George A. and Christine M. Evan - Page 18

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          evidence at trial and presented only legal arguments to the                 
          Court.                                                                      
               As noted above, because of the fire in petitioners’                    
          residence and the damages that resulted, the parties stipulated             
          summaries of information provided by petitioners during                     
          respondent’s audit to support the claimed expense deductions                
          reported for 1997.  The parties did not stipulate any summaries             
          for 1998.                                                                   
               We find that the summaries are inadequate to substantiate              
          the claimed deductions.  For example, we find petitioners’ use of           
          the same mileage and parking fee for each school visited and                
          their claim that they visited each school in alphabetical order             
          implausible.  Also, as support for the travel expenses,                     
          petitioners provided, for the most part, their own written and              
          oral testimony.  For the few receipts that were provided for the            
          trips (most notably, two trips to Florida taken in mid-March and            
          late December), petitioners offered only testimony that the trips           
          were for the purpose of job-hunting or continuing education.  We            
          find that petitioners’ proffered testimony does not qualify as              
          reasonable secondary evidence to replace that required by the               
          stringent record-keeping rules of section 274(d).                           
               Petitioners argue that these expenses were necessary for Mr.           
          Evan to maintain and improve his skills as a professor and to               
          keep his real estate license active, a requirement for teaching             
          real estate and appraising.  Although, according to the                     
          summaries, petitioners did provide receipts for some expenses, we           





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